The decision
How the matter was handled
Royal Decree 316/2026 added to the Immigration Regulation a route that did not exist before: temporary residence on exceptional grounds under the twenty-first additional provision, designed for situations of vulnerability. It was approved on 14 April 2026.
Our client, from Egypt and living in Madrid, met the requirements of that route. The trouble with a brand-new provision is that there are no earlier files to learn from: every piece of evidence has to be built from the text of the rule itself, without knowing what the case officer will ask for. We prepared the application and filed it in April 2026.
The Directorate-General for Migration Management granted it in September 2026: 125 days between filing and signature.
The permit runs for one year, takes effect from the day of the application — not the day it was granted — and allows the holder to live and work anywhere in Spain, as an employee and self-employed alike. It is the first case under this route that we publish.
Every case is unique: it depends on its facts, its evidence and the authority deciding it. The outcome of one matter does not anticipate the outcome of any other, and the timescales given here are the ones that particular file took: they are set by the authorities, not by us.